Thirty percent in banks, or 60% for significant tokens

MiCA's current reserve framework requires a minimum portion of the relevant stablecoin reserves to be held as deposits with credit institutions. The floor is 30%, increasing to 60% for stablecoins classified as significant.

The requirement was designed in part to support reserve liquidity and reliable redemption. It also creates a direct balance-sheet connection between stablecoin issuers and commercial banks.

In its collective response to the European Commission's MiCA review consultation, the European System of Central Banks — the ECB plus the national central banks of all 27 EU countries — recommends removing that mandatory minimum deposit allocation.

The central banks see risk on the bank side too

The ESCB's argument focuses on the structure of bank funding. As stablecoins become larger, their issuers can place substantial reserve deposits at a relatively small number of banks. Those concentrated balances may behave very differently from a broad base of retail deposits.

A wave of stablecoin redemptions forces an issuer to mobilize reserve assets. If a large portion sits at a commercial bank, substantial deposits may have to be withdrawn quickly. The ESCB argues that the current rule can therefore replace comparatively stable retail funding with deposits that are more concentrated and sensitive to market conditions.

Contagion can run in the opposite direction as well. The ECB has previously pointed to the March 2023 failure of Silicon Valley Bank: part of USDC's reserves was held at the bank, and uncertainty over access to those assets contributed to the stablecoin temporarily losing its dollar peg.

The alternative targets maturity rather than lower backing

Instead of fixed bank-deposit percentages, the ESCB recommends minimum requirements for reserve assets maturing within periods of one to five working days. Regulation would focus more directly on how rapidly an issuer can generate liquidity.

Very short-duration securities and certain reverse-repurchase transactions could provide liquidity without automatically concentrating the same share of stablecoin reserves in commercial bank deposits.

This is not a proposal to abandon reserve backing. MiCA imposes prudential requirements on issuers of asset-referenced tokens and e-money tokens covering the value, composition, custody and liquidity of reserve assets. The policy dispute concerns their composition and the best way to ensure liquidity under stress.

The EBA also wants the deposit requirement reviewed

Two days after the ESCB submission, the European Banking Authority published its own priorities for the MiCA review. It described the existing requirements for ART and EMT issuers as broadly appropriate but also recommended reviewing minimum reserve deposit requirements while preserving effective risk management.

The EBA's response provides a useful snapshot of the regulated EU market. As of September 1, 2026, 39 e-money tokens had been issued under MiCA, while no asset-referenced token had yet been authorized under the framework.

The two institutions therefore converge on reviewing the deposit rule, but that agreement does not itself amend European law. The Commission has to assess consultation responses before any MiCA changes can proceed through the EU legislative process.

Global multi-issuer stablecoins remain the harder problem

The ESCB takes a stricter position on so-called multi-issuance arrangements. Under this structure, the same stablecoin organization can issue tokens through an EU entity and a third-country entity while treating the resulting tokens as interchangeable.

European central banks are concerned that such fungibility can shift redemption pressure toward the EU issuer. European reserve assets could potentially be called upon to satisfy redemptions associated with tokens originally issued outside the Union.

According to the ESCB response reported by Reuters, those structures are not permitted under the current MiCA framework. If the EU were to permit them in the future, the central banks want a comprehensive safeguard framework, including an assessment of whether the relevant third country's stablecoin regime is equivalent.

The EBA leaves room for equivalence with additional safeguards

The EBA's September 24 response leaves more room for an internationally structured regime. It sees potential merit in an equivalence framework for global stablecoins, provided equivalence operates alongside additional risk-mitigation measures.

Its considerations include reserve composition, redemption rights, supervisory information exchange and cooperation, as well as retaining powers for EU authorities to address risks on a case-by-case basis. The EBA also notes that relatively few third countries have made substantial progress in implementing international recommendations for global stablecoin arrangements.

The debate is therefore more complex than simply allowing or banning global stablecoins. European authorities are examining ways to prevent an EU reserve pool from becoming an uncontrolled redemption backstop for liabilities created in other jurisdictions.

Enforcement is another concern

The ESCB also reports material challenges in enforcing MiCA. Crypto firms were required to obtain the necessary EU authorization or wind down relevant operations in the bloc by June 2026, subject to the applicable transitional arrangements.

European central banks nevertheless say non-compliant businesses continue to reach EU customers. They identify resulting investor-protection concerns alongside the prudential questions surrounding stablecoin reserves.

MiCA has not changed yet

For issuers, the most important qualification is straightforward: the existing thresholds still apply. The ESCB paper is a consultation response and the EBA document is another contribution to the MiCA review. Neither document directly repeals the 30% or 60% requirement.

Any replacement has to move through the European regulatory and legislative process before it becomes applicable. An issuer cannot simply substitute MiCA's current deposit minimum with a portfolio of short-maturity securities because European central banks now prefer a liquidity-based approach.

The policy shift is still significant. Reserve regulation is moving beyond the question of whether every token is backed. The next debate is about where that backing sits, how quickly it can become cash and what happens to the institution holding it when a large stablecoin faces a rush of redemptions.